ML20058A890
| ML20058A890 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 11/17/1993 |
| From: | Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Wallace M COMMONWEALTH EDISON CO. |
| Shared Package | |
| ML20058A893 | List: |
| References | |
| EA-93-235, NUDOCS 9312010290 | |
| Download: ML20058A890 (6) | |
See also: IR 05000374/1993025
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UNITED STATES
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November 17, 199?
Docket No. 50-374
License No. NPF-18
EA 93-235
Commonwealth Edison Company
ATIN:
Mr. Michael J. Wallace
Vice President,
Chief Nuclear Officer
Executive Towers West 111
1400 Opus Place, Suite 300
1
Downers Grove, IL 60515
Dear Mr. Wallace:
SUBJLCl:
LASALLE COUN1Y STATION - UNIT 2
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL
PENALTY - 5112,500
(NRC INSPECTION REPORT NO. 50-374/93025(DRSS))
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This refers to the special safety inspection conducted during the period of
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September 8 through 14, 1993, at LaSalle County Station, Unit 2.
The purpose
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of the inspection was to review a significant radioactive' contamination event
which occurred during reactor vessel disassembly on September 7,.1993.
The
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report documenting this inspection was'sent to you by letter dated September
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27, 1993.
During the inspection, violations of NRC. requirements were
identified.
An enforcement conference was held on October 5,'1993, to discuss the apparent
violations, their causes and your corrective actions.
The report summarizing
the conference was sent to you by letter dated October 13, 1993.
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On September 7, 1993, three crews (eight workers) were assigned to the Unit 2
reactor cavity to disassemble the reactor vessel head with pneumatic tools. A
pre-job meeting which included the maintenance foreman, workers and three
radiation protection technicians (RPIs) assigned to cover the job was. held.
However, the discussion of radiological controls was limited.
Initially, two
RPIs were covering the job from the refueling floor.
The RPIs did not enter
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the cavity and air sampling of the reactor cavity was not performed.
Even
though contamination levels exceeded. 100,000 dpm/100cm2 _in what should have
been considered the work area, the workers were not wearing respirators as
required by procedure for work areas with such. contamination levels.
In
addition.. engineering controls were not used.to limit airborne radioactivity
in the cavity.
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A third RPT relieved one of the RPIs (RPT #1) on the refueling floor, and
noticed that one of two continuous air monitors on the floor was alarming.
About the same time, RPT #1 notified the refueling floor that his face was
contaminated. Operations had previously secured the Unit 2 Reactor Building
ventilation system to perform a scheduled surveillance approximately 15
minutes earlier.
CERTIFIED MAIL
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RETURN RECElf REQUESTED
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The workers were notified and exited the refueling iscor, and the refueling
floor coordinator requested Operations to restart the ventilation system.
Shortly thereafter, contamination was detected in various levels of the Unit 2
reactor building due to air flow through gaps in the refueling floor equipment
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hatch.
In total, 22 workers were contaminated during the event,17 of whom
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received mear.urable intakes of radioactive material .
Three violations were identified as described in the enclosed Notice of
Violation and Proposed Imposition of Civil Penalty (Notice).
The violations
involve: (1) failure to adequately evaluate the job and make necessary surveys
of the reactor cavity while the job was in progress; (2) failure to use
engineering controls to limit airborne radioactivity in the reactor cavity;
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and (3) failure of the workers to wear respirators in accordance with
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radiation protection procedures.
The root causes of the event included inadequate planning which resulted in
the failure to adequately evaluate the radiological hazards associated with
the reactor vessel disassembly.
The ALARA review for the job was cursory and
did not consider the potential changing radiological conditions in the cavity.
There was a clear lack of management and first line supervisory oversight of
the RPTs.
Contributing factors included ineffective training of the RPIs and
radiation workers, the lack of a questioning attitude of RPIs and workers
concerning the work environment, poor communications, a lack of understanding
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of how the reactor building ventilation system's operation affects
radiological conditions, and an inadequate review of Information Notice 92-75.
The root causes of this event are similar to those associated with the failure
to make appropriate surveys which resulted in administrative overexposures on
December 17, 1991 (EA 92-003).
Your corrective actions documented in your.
February 1992 response to the enforcement conference and Notice of Violation-
were ineffective in preventing recurrence, and a lack of management
involvement allowed inconsistent performance of'the radiological controls
program to persist.
I am particularly concerned because I brought to your
attention at the August 20, 1993, public Systematic Assessment of Licensee
Performance (SALP) meeting, clear precursors of poor radiation protection
program performance.
These included the lack of management and supervisory.
oversight illustrated by the station Radiation Protection Manager not entering
-the radiologically controlled area during the first eight months-of 1993,
rece_nt radioactive waste spills, and continued observations'of poor radiation
worker _ performance,
fu thermore, we are concerned'that performance after this event has'~ continued
I poor.- ' Specifically, we continue to seel disturbing radiation protection
wirk practices during our plant tours, including two cases of radiation
workers not following specific' job instructions to contact radiation--
protection before commencing work.
We are concerned that this continuing' poor
performance may stem from your underestimating the depth and breadth of the
underlying problems as illustrated by what appeared to be an overly optimistic
portrayal of the present situation at the enforcement conference.
It appears
that-the continuing problems are due, in part, to. poor individual performance
by RPTs and other radiation workers; these problems raise fundamental
questions about the attitude of station workers'towards radiation hazards.
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Commonwealth Edison Company
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November 17, 1993
This situation requires sustained and intensive management oversight and
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involvement in radiation work activities.
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We acknowledge your corrective actions for the violations, which included but
were not limited to: implementation of the lead technician program for the
refuel floor by a qualified manager, ensuring continuity is provided when new
programs are implemented, conducting one-on-one discussions with the RPTs to
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review the event and management expectations, developing an administrative
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controls guide for the refuel floor, reconsidering the need for localized
ventilation units during reactor vessel disassembly, and extensive actions to
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address programmatic and radiation orotection attitude issues.
However, we
are concerned that you apparently underestimated the scope of the problems
that you face, your training initiatives were not sufficiently comprehensive
in that no feedback mechanism was included to assess effectiveness, and you
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did not address improvements for reviewing NRC information notices.
We recognize that the radiation doses received by the workers during the event
were within regulatory limits.
Nevertheless, based on the concerns discussed
above, the violations are classified in the aggregate as a Severity Level Ill
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problem in accordance with the " General Statement of Policy and Procedure for
NRC Enforcement Actions," (Enforcement Policy) 10 CFR Part 2, Appendix C.
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To emphasize the need for management involvement an' - ersight of the
radiation safety program, I have been authorized I". . consultation with the
Director, Office of_ Enforcement, to issue the enclosed Notice of Violation and
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Proposed Imposition of Civil Penalty (Notice) in the amount of $112,500 for
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the three violations that constitute a Severity Level Ill problem. . The base
value of a civil penalty for a Severity Level III problem is $50,000. Tho
civil penalty adjustment factors in the Enforcement Policy were considered,
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-The base civil penalty was mitigated 25 percent because.your staff
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demonstrated initiative in identifying the root causes of the violations
resulting in. this self-disclosing event.
In particular, the immediate actions
of the involved radiation protection personnel in pursuing the initial
indications of the problem demonstrated a questioning attitude.
The base
civil. penalty was not~ mitigated for your corrective actions because we had
concerns in this area, as discussed above,
lhe base civil penalty was escalated 50' percent for your poor past
. performance. A number of problems ~ have been identified in the last two years
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including a. contaminated area posting being cut down and discarded (8/93),
three liquid radioactive waste spills which~ resulted in the signif.icant spread
of contamination (6/93 and 8/93), a violation'for workers not adhering.to a
radiation work permit'(11/92), and the administrative overexposures discussed
above (12/91),
The base civil penalty was escalated 100' percent for prior opportunity to-
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identify. - NRC Information Notice' 92-75 was issued in November 1992 and .
alerted licensees to enplanned personnel intakes of radioactive materials
because of inadequate radiological, engineering, and procedural controls for
contaminated areas.
The Information. Notice emphasized the need for vigilance
.in conducting maintenance activities that could significantly increase
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November 17, 1993
airborne radioactive material.
Furthermore, as noted earlier, clear
precursors of poor radiation protection program performance were brought to
your attention at the SALP meeting.
The other adjustment factors in the Policy were considered and 60 further
adjustment to the base civil penalty is considered appropriate.
Therefore,
based on the above, the base civil penalty has been increased by 125 percent.
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You are required to respond to this letter and should follow the instructions
specified in the enclosed Notice when preparing your response.
In your
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response, you should document the specific actions taken and any additional
actions you plan to prevent recurrence.
After reviewing your response to this
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Notice, including your proposed corrective actions and the results of future
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inspections, the NRC will determine whether further NRC enforcement action is
nece.ssary to ensure compliance with NRC regulatory requirements.
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of
this letter, its enclosure, and your responses will be placed in the NRC
Public Document Room.
The responses directed by this letter and the enclosed Notice are not subject
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to the clearance procedures of the Office of Management and Budget as required
by the Paperwork Reduction Act of 1980, Public Law No.96-511.
Sincerely,
Original Signed By
John B. Martin
Regional Administrator
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Enclosure:
Notice of Violation and Proposed
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Imposition of Civil Penalty
See Attached Distribution
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November _17, 1993
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Distribution:
cc w/.,iclosure:
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L. DelGeorge, Vice President,
Nuclear Oversight and Regulatory
Services
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W. Murphy, Site Vice President
J. Schmeltz, Acting Station Manager
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J. Lockwood, Regulatory Assurance
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Supervisor
D. ~ f arrar, Nuclear Regulatory
Services Manager
OC/LFDCB
Resident inspectors, LaSalle,
Clinton, Dresden, Quad Cities
R. Hubbard
J. .W.
McCaffrey, Chief, Public
Utilities Division
Licensing Project Manager, NRR
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R. Newmann, Of fice of Public Counsel-
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State liaison Officer
Chairman, Illinois Commerce
Commission
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November 17, 1993
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DISTRIBUTION
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Enforcement Coordinators
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